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Facts:
• FQHC “look-alike” to provide county
health clinic technology-related
equipment and services to facilitate
telemedicine encounters with county
clinic’s patients
• Items and services paid for using
State Department of Health grant
• Telemedicine items and services
used only for encounters related to
HIV prevention, including
prescription of meds for pre-
exposure and post-exposure
prophylaxis
• County clinic could use telemedicine
items to refer to FQHC-like provider
or other providers
• Both parties may submit claims to
federal payers
Analysis:
• Safeguards against patient steering,
including no referral requirements between
parties or to a provider’s pharmacy
• None of the telemedicine technology would
limit or restrict compatibility with other
technologies
• Unlikely to increase costs to federal payers
because billed items/services would have
been provided regardless of the
arrangement
• Increased access to preventative services
primarily benefit patients, not the providers
Advisory Op. 18-03